Not nice - but I sort-of understand what they're saying, and I must admit that I half expected it. They're currently putting huge
pressure on manufacturers and car buyers to go for the lowest emission options, but letting kit builders get away with installing ancient engines that
get nowhere close to the current standards.

Note that I'm saying this as the owner of a Locost with a 1970's Ford crossflow engine...

Really, really hope that if this proposal is passed (quite likely) they are fair enough to give us builders part way through their builds a couple of
years to get it finished off and through IVA.

Our kitcar builders opinions are being voiced through some of the larger kitcar/sportscar manufacturers such as westfield - will they fight the corner
for the complete self-builder (build chassis from scratch) or will they jump at the opportunity to stop self-builds to increase their own sales?

I’m not surprised by this they where always going to tighten up the regulations kitcars will still pass this with modern engines I think everyone
should remember how lucky we are to be able to build cars in this country!

This a result of the blanket adoption of EU law to align UK law prior to Brexit.

Point 10 below needs to be addressed urgently and I suggest that argument is discussed urgently and not at length or we will simply miss the deadline
for response.
One of the big problems with the latest engines is the complexity of the ECU and the built in security systems that require sight of dashboards,
antilock brake sensors and a whole lot more that stops us from recycling cars that would just be scrapped.
There is a big conversation to be had and we don’t have much time.

10 Are you content with our proposal to require kit cars to meet the latest MOT standards, removing the current rule where vehicles are tested to MOT
standards according to the age of their engine?

The consultation period begins on Friday 2 February 2018 and runs until Friday 2 March 2018. Please ensure that your response reaches us before the
closing date. If you would like further copies of this consultation document, it can be found at https:// www.gov.uk/dft#consultations or you can
contact us using the details below if you need alternative formats (Braille, audio CD, etc.).

Is anyone here prepared to draft a letter we could all use as a template to lodge our objections to this?

What precisely are you objecting to?

The whole document is talking about new IVA tests, so unless there is something I've missed, retrospective application to vehicles that already
have an IVA pass doesn't seem valid.

As far as I can tell, if you have a post September 2002 engine, then this proposal makes no difference whatsoever, as you are already required to meet
the most stringent MOT standard during IVA.

What I think they're proposing in effect is the removal of the CAT 1 test from the IVA and make passing the BET test (which is the first
emissions test you go through) mandatory.

What seems to have been assumed by the DfT in section 4.13 is that for any powertrain that meets at least Euro 1 standards (i.e. August 1992 on), then
it can meet the September 2002 MOT standards.

NB: this assumes that the registration date is not in the past. Contrary which has been posted on that FB group, this is not necessarily restricted to
brand new 67 / 18 registrations. There are age related and Q plated kits with registration dates that are the same time as their IVA / registration
dates.

The proposal is for your cars emission requirements to not be engine age specific but to match that of the mot requirements at time of
registration.
In a nutshell you’ll need a catalytic convertor, fuel injection and a very well setup ECU with emissions in mind.

I eat to survive
I drink to forget
I breath to wee my ex wife off (and now my ex partner)

Is anyone here prepared to draft a letter we could all use as a template to lodge our objections to this?

What precisely are you objecting to?

I would be objecting to its immediate implementation if it is passed. Your summary of the proposed changes is excellent (thank you) and I shouldn’t
have too many issues with this (year 2000 BMW engine with cat), however, many other builders are mid-way through their builds using engine setups that
are unlikely to pass these stringent emissions tests. If it is passed I would be wanting a few years before the new emissions limits come into force.

quote:Originally posted by snapper
In a nutshell you’ll need a catalytic convertor, fuel injection and a very well setup ECU with emissions in mind.

It is more than just this - even if you have a post August 1995 to pre September 2002 engine (and hence most likely have a catalyst and EFi fitted
already), your targets also change with this proposal.

This is a consultation document
We have the opportunity to comment
It is a proposal and with any change in motoring Law is not retrospective in the same way that emissions requirement is not retrospective for older
cars

I eat to survive
I drink to forget
I breath to wee my ex wife off (and now my ex partner)

Personally for me at the moment this isn't a problem as mine is registered and running the standard Ford ECU with a CAT but obviously those that
are in the process of building with an older engine this is a concern.

Would a zetec running say an Omex/Emerald ECU and a CAT meet the emission standards easily enough or would even that struggle?

I can see the point of the change, but will be writing with the following objections/comment. Of course I am entirely motivated by the fact that I
don't want this to come in before I get my car finished - as I am fully intending to use a 1985 Ford Pinto engine running carbs, which I assume
won't meet modern emission standards. But, incase, I have decided to try and get my car to IVA as soon as possible now!!!

1 - At best a change like this should have a reasonable lead time - say 24 months - because many people build kit cars over a reasonably long period
of time - and many will have begun such projects expecting to use an engine which, under the new rules will not be allowable.
2- The actual impact from an environmental point of view of implementing this change will be minimal. Of the relatively small number of kit cars which
are being built and used on the road, many already have engine which can meet modern emissions standards.
3 - Once registered many kit cars are used for a relatively small amount of miles each year (evidenced by the fact that many kit cars are insured on
limited mileage policies), and therefore even those with engines tested to older standards will make little environmental impact in real terms.
4- If it is deemed necessary to implement this change, a reasonably long lead time to implementation should be considered acceptable because of 2) and
3) above.

Does this proposed change impact at all on the use of bike engines, especially on Morgan-like trike builds? I'd like to build one of those
next...